Transfer pricing

21st-Century Transfer Pricing

Transfer pricing is an area that raises the most questions and doubts among entrepreneurs conducting transactions with related parties. It is not only a documentation obligation imposed by regulations but also an important element of a company's financial security.

Transactions between related companies are subject to particularly close scrutiny by tax authorities. Any deviation from market conditions can result in the denial of deductions and the imposition of high penalties. Therefore, transfer pricing documentation is more than a formality; it's a protective shield against tax risk.

Basic support scope

Transfer pricing documentation preparation (local, group, TPR).

Marketability analysis of transactions and benchmarks.

Advisory on Restructurings and Intra-Group Transactions.

Who will benefit from professional transfer pricing services?

The so-called TP documentation does not only apply to the largest corporations. The obligation to document them covers an increasingly wide range of companies. If your business involves transactions between related entities, it is worth using professional support to avoid errors and tax penalties.

The transfer pricing service process at ATF Tax is designed to ensure full compliance with regulations, transparency, and tax security for the Client.

We implement each stage in close cooperation with the entrepreneur, guaranteeing the precision of analyses and practical support in communication with tax authorities.

Step 1

Transaction and group structure analysis

We identify related parties and the scope of transactions subject to documentation requirements.
We are verifying billing schemes and financial flows within the capital group.
We assess tax risks and compliance with transfer pricing regulations.

Step 2

Documentation and comparative analysis development

We are preparing local documentation (Local File) and group documentation (Master File).
We perform comparative analyses (benchmarking) based on market data.
We are developing a transfer pricing policy tailored to the client's business specifics.

Step 3

Reporting and communication with tax authorities

We prepare and file TPR forms and transfer pricing compliance statements.
We represent clients during tax audits and transfer pricing proceedings.
We support you in dealing with the tax administration and prepare necessary explanations.

Ensure your company peace of mind and security in the area of transfer pricing.

FAQ

Many entrepreneurs ask when it is worth using the help of a tax advisor, what services tax consulting for companies includes, and what real benefits cooperation with ATF Tax experts can bring.

What does tax consulting for companies involve?

Tax advisory services provide comprehensive assistance with CIT, PIT, and VAT taxes. This includes analysis of tax returns, preparation of declarations, tax planning, representation before tax authorities, and ongoing support for current matters.

When is it worth using the services of a tax advisor?

It's always worth using the help of a consultant when a company is growing, planning investments, changing its tax system, or entering new markets. Tax consulting is also invaluable when implementing Estonian CIT, using tax reliefs, restructuring a business, or preparing for tax audits.

Is online tax advice effective?

Yes – online tax consulting is the standard today. It allows you to consult with experts from anywhere in Poland (e.g., Poznań, Warsaw, Krakow, Gdańsk), send documents, and receive recommendations electronically. It's a fast, convenient, and secure solution that provides the same level of support as in-person meetings.

What is the difference between a tax audit and standard tax consulting?

Tax audit is a detailed analysis of tax returns that allows for the detection of errors, identification of risks, and indication of areas where savings can be achieved. Tax consulting, on the other hand, is ongoing, continuous service that includes monitoring regulations, advising on business decisions, and implementing legally compliant solutions. At ATF Tax, we combine both services so that your company operates securely and predictably.

Tax reliefs and preferences offer several benefits: * **Reduced Tax Liability:** The most direct benefit is a lower amount of tax owed. This can free up money for other uses. * **Increased Disposable Income:** With less tax to pay, individuals and businesses have more money available for spending, saving, or investing. * **Incentive for Certain Behaviors:** Tax reliefs are often designed to encourage specific activities, such as: * **Investment:** Tax breaks on investments can encourage capital formation and economic growth. * **Saving for Retirement:** Tax-advantaged retirement accounts encourage individuals to save for their future. * **Charitable Giving:** Tax deductions for donations incentivize philanthropy. * **Homeownership:** Deductions for mortgage interest can make buying a home more affordable. * **Education:** Tax credits or deductions for educational expenses can make schooling more accessible. * **Support for Specific Industries or Groups:** Governments may use tax preferences to support particular sectors of the economy or groups of people, such as small businesses, low-income households, or specific industries deemed important for national interests. * **Stimulation of Economic Activity:** By leaving more money in the hands of consumers and businesses, tax reliefs can boost demand and encourage economic activity. * **Simplified Tax Compliance (sometimes):** While not always the case, some reliefs can simplify tax calculations for individuals or businesses meeting specific criteria. In essence, tax reliefs and preferences are policy tools used by governments to influence economic behavior, redistribute wealth, and promote specific social or economic goals.

Properly applied tax reliefs (R&D, IP BOX, investment relief, expansion relief) can significantly reduce tax liabilities. Our advisors help to determine which reliefs a company can benefit from, prepare complete documentation, and ensure correct settlement, leading to real savings for entrepreneurs.

Does tax consulting also include international taxes?

Yes, we advise on international taxation – from avoiding double taxation and handling VAT settlements in foreign transactions, to withholding tax (WHT) matters. Our tax advice for companies operating abroad helps you conduct international business safely and minimize tax risks.

What are the benefits of implementing Estonian CIT?

Estonian CIT allows a company to postpone tax payments until profit is distributed. This enables the business to invest funds in development and maintain greater financial liquidity. We help assess whether Estonian CIT is beneficial for your company, implement the solution, and ensure compliance with regulations—from the initial analysis to ongoing settlements.

Do tax advisors represent companies before tax authorities?

Yes, at ATF Tax, we represent our clients at every stage of contact with tax authorities, including all stages of tax proceedings and before administrative courts. We prepare responses, requests for individual interpretations, and file appeals against decisions, ensuring the protection of the entrepreneur's interests.

Can business restructuring provide tax benefits?

Yes, corporate restructuring often allows for the organization of tax liabilities, reduction of debt, and recovery of financial liquidity. We advise on tax restructuring, combining legal, financial, and tax knowledge so that the company can safely begin a new phase of operations.

How much does tax consulting cost?

The cost of tax advisory services depends on the scope of services and the complexity of the case. We charge hourly for simple consultations, while audits, implementations, or international support are priced individually. In every case, we guarantee transparent cooperation terms and clear communication without hidden costs.